Bank of America, N.A. v. JB Hanna, LLC
766 F.3d 841
| 8th Cir. | 2014Background
- Hanna Parties borrowed multi-million dollars from Bank of America, secured by real property and guarantees, with multiple intertwined loan and swap agreements.
- The 2005 JB Hanna loan and its related 2005 swap had a maturity mismatch, with a 2010 loan maturity and a 2015 swap term, raising concerns about alignment of terms.
- The Bank declared default when JB Hanna failed to pay the 2005 loan at maturity (Sept. 20, 2010) and cross-defaults were triggered across related agreements.
- Hanna Parties asserted defenses including waiver, prior breach, and good-faith/fair-dealing; the district court granted summary judgment against those counterclaims.
- Trial proceeded on breach-of-contract and related claims; the jury found no breach by Hanna parties, and the district court entered judgment for Hanna Parties; Bank motions post-trial were denied.
- Ultimately, the panel reversed in part, ordering a new trial on the Bank’s breach-of-contract claims, while upholding summary judgment on counterclaims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jury-trial waiver scope and applicability | Bank argues waivers in related documents extend to 2005 loan | Hanna contends waiver does not extend to the 2005 loan due to separate transaction | Hanna not shown to waive jury trial for 2005 loan |
| Rule 50(b) renewal on post-verdict motion | Bank preserved preverdict grounds via Rule 50(a) motion | Hanna asserts district court erred in denying post-verdict motion | District court properly denied Rule 50(b) motion for lack of preverdict Rule 50(a) motion |
| Great weight of the evidence; new trial standard | Verdict supported by evidence; no basis for new trial | verdict against great weight of the evidence; new trial warranted | District court abused discretion; remanded for new trial on breach-of-contract claim |
| Fraud, fiduciary duty, negligence, deceptive trade practices counterclaims | Statute of limitations bar and merits support | Claims timely or with tolling; merits shown | Summary judgment upheld for Bank on these counterclaims |
| Reformation and misalignment of term; mutual mistake | Reformation warranted due to mismatch of terms | No meeting of minds; no basis for reformation | Reformation counterclaim was properly rejected; no reversible error |
Key Cases Cited
- Indus. Lumbermens Mut. Ins. Co. v. Timberland Pallet & Lumber Co., 195 F.3d 368 (8th Cir. 1999) (fundamental Seventh Amendment waiver principles; presumption against waiver)
- Aetna Ins. Co. v. Kennedy, 301 U.S. 389 (U.S. 1937) (Seventh Amendment rights are fundamental and may not be easily waived)
- Shapiro v. Marstone Distribs., 337 N.Y.S.2d 928 (N.Y. App. Div. 1972) (waivers cannot bind non-signing related parties in multi-party instruments)
- Catlett v. Local 7370 of United Paper Workers Int’l Union, 69 F.3d 254 (8th Cir. 1995) (preverdict Rule 50(a) requirements and substantial compliance)
- Johnson v. New York, N.H. & H. R. Co., 344 U.S. 48 (U.S. 1952) (need for new trial as remedy in exceptional cases)